Most industrial facilities with combustion systems (incinerators, power plants, refineries, etc.) are not required to regularly test for most of the chemical pollutants they release. Facility operators will draw attention to the idea that they have continuous emissions monitors (CEMs), that engineers in a control room are constantly paying attention to their emissions, making sure they're within legal limits and that state regulators are hawkishly looking over the numbers and will fine the heavily if they exceed any limit. The reality is quite different.

Typically, only a few pollutants are tested continuously... usually Nitrogen Oxides (NOx), Carbon Monoxide (CO) and Sulfur Dioxides (SO2). Oxygen and various operating parameters like temperature are also typically monitored on a continuous basis. Sometimes continuous monitoring is required for opacity (an indirect way to measure particulate matter), hydrochloric acid or, more recently, mercury or particulate matter.

The most toxic pollutants are typically tested only yearly, if at all. Such infrequent testing (under ideal operating conditions) allows for easy manipulation of test results and is known to underestimate real emissions (see the Dioxin CEMs page for docmentation).

If we regulated speeding the way we do smokestacks, annual stack testing is like setting a speed limit and allowing drivers to drive all year with no speedometer. Once a year, on the highways, a speed trap would be set, with signs leading up to it warning 'slow down... speed trap ahead' ...and letting the driver's brother run the speed trap (the companies do their own testing). In reality, smokestack facilities are 'speeding' many other days of the year, with excessive emissions during startup, shutdown and malfunction times, when testing is not done. Regulating air polluting facilities in this manner is inexcusable, especially in the age where continuous testing technology exists and where the data is able to be made available to the public real-time through a website.

Currently, the technology exists to continually monitor a long list of pollutants, including toxic metals, acid gases, dioxins, particulate matter and more (see sidebar).

Any corporation that claims that their facility's emissions will be within certain limits should be put to the test by asking that they install CEMs to provide real-time emissions data to back up their claims. All CEM data ought to be made available real-time on a publicly-available Internet website, as a condition of state permits. Where state agencies are unwilling to require such disclosure, local governments ought to pass laws to provide such requirements, as has been done with local ordinances in Pennsylvania.

Dioxin emissions monitors were tested and verified by EPA in June 2006. See EPA's Dioxin Monitoring reports. Some of these are actually real-time monitors, while other are semi-real-time or are long-term samplers. Long-term sampling allows for a complete picture by collecting the sample for periods of up to 30 days. This makes it possible to take 12 samples per year, collecting a complete picture of actual dioxin emissions. Research from the UK found that AMESA's continuous sampling shows higher dioxin emissions than typical stack tests, and research from Belgium shows that the difference can be 30-50 times higher. This is largely because annual stack tests are not done when dioxin emissions are known to be the highest, during start-up, shut-down, and malfunction times, when air emissions permit limits do not even apply and no monitoring is usually done. Dioxin formation is highly temperature-sensitive, which is why it's important not only to have continuous monitoring to show the real emissions levels, but to have real-time feedback to operators so that they can adjust the operating conditions to minimize dioxin formation.

EPA's dioxin CEMs factsheet states: "Long-term continuous samplers collect samples over time periods up to several weeks to obtain a cumulative record of source emissions and provide evidence of emission levels. Real or semi-real-time continuous monitors, with a frequency of measurement at real time or up to an hour, provide quick feed back to the plant operator by measuring dioxin emission levels on-site." AMESA is one of two long-term samplers EPA has tested and verified. IDX Technologies has a laser-based real-time dioxin monitor that EPA has tested and verified.

The other two proposed waste coal-fired power plants planned for Pennsylvania would have also been required to use CEMs for PM10, but the southwest regional office of the PA DEP ignored comments by ActionPA and three federal agencies (U.S. EPA, USDA Forest Service and the National Park Service) and chose not to require this, as the northcentral PA DEP regional office did of the River Hill plant.

Here's an excerpt from the National Park Service comments on the Greene Energy Resource Recovery Project:

"Compliance Monitoring

We recommend that a filterable PM10 limit and Continuous Emissions Monitor (CEM) requirements be added. For example, the West Virginia Division of Air Quality (WVDAQ) has included both filterable and condensable PM10 in its permit limit for Longview Power, and proposed that PM emissions be monitored by a CEM within 18 months of boiler start-up or when performance specifications for such monitors are promulgated, whichever comes later.[1] We continue to believe that CEMs are an important tool for monitoring compliance. For that reason, we recommend that a PM CEM be installed upon startup.

[1] Those CEM Performance Specifications were later promulgated by EPA on 1/12/04."

EPA's comments submitted on 3/11/2005, were as follows:

"The proposed plan approval requires annual stack testing to assure compliance with the particulate matter emission limits from the CFB and its associated fabric-filter baghouse. In light of the evolution of CEMS systems for particulate matter, EPA is strongly urging the requirement to install and operate a particulate matter CEMS at the proposed facility. Currently, there are several facilities that operate PM CEMS and have demonstrated that the systems are reliable and accurate. These are Tampa Electric power plant (Florida), Eli Lilly Corporation (Indiana), and the U.S. Department of Energy (Tennessee). EPA has also secured commitments from up to 30 existing coal-fired utility installations to install PM CEMS over the next couple of years. It is fair to assume that the state of technology for PM CEMS will be even further evolved by the time the proposed Robinson Power facility begins operation. Further, the facility will be required to establish a compliance assurance monitoring plan (CAM) as part of its title V operating permit and the federal CAM regulations strongly encourage reliance on continuous monitoring systems as a means for assuring compliance. Also, the upcoming re-designation of the area to nonattainment for PM2.5 suggests that more timely and accurate data regarding PM emissions from the proposed facility would be important information."